National Flood Policy—ASFPM 2015 Recommendations
L. Coastal Issues
L.1. Share/redirect navigation fuel tax for coastal
and aquatic habitat restoration
Maria is correct: we need to order the recs
Honeycutt: General comment on organization:
Assuming the order of recs now is random, merely
compiled from earlier source docs. If not already
planned by section author, strongly recommend a
reordering that considers relative import / impact
of the recommendation, with implementing
entity/entities as a secondary organizing principle.
Also consider integrating beach nourishment (W)
into this section, in as much as it’s one of many
tools for managing coastal risk and raising
economic questions/concerns. We need to ensure
there’s harmony in what we advocate in other recs
(e.g., L4); beach nourishment is often a tool used
in conjunction with other methods (strategic
retreat, structural measures, living shorelines,
etc.). See comment from S. Boehning on L4(a) on
this issue.
From S. Boehning:
This may already be occurring through USACE
programs. For example, USACE maintains federal
navigation inlets and participates in coastal
restoration where inlets have adversely impacted
the shoreline. In Florida, local inlet districts for
non-federal inlets should/are mitigating impacts.
From Steve Eberbach: Question for authors: Does
ASFPM have a preference as to whether this is a
local- or state-enforced tax?
As minimum requirement, jurisdiction must have
on the books and enforced a provision that any
new permit for creation of a waterway or road to
support resource exploration must be mitigated
(filled in and repopulated/stabilized with endemic
species).
Permitted resource mining activities must pay
independent entity to track the subsidence during
the extraction period and mitigate the loss of flood
risk protection lost due to that subsidence.
L.2. Provide preferential support (grants and cost
share) and other incentives to states & localities
whose policy is strategic retreat from the
shoreline. Encourage all coastal states to plan for
NFPPR Combined comm rec and comments
Composite comment from multiple people:
It is unreasonable and unrealistic for ASFPM to call
for the abandonment of barrier islands. Our policy
recommendations need to be grounded in reality.
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sea level rise and develop and implement a long
term plan to prevent future development and
relocate existing development from [highest risk]
barrier islands and low lying areas vulnerable to
sea level rise and other coastal flood hazards.
Preserve these areas for natural floodplain
functions, natural resources, and outdoor public
enjoyment.
L.3. Establish a national policy with minimum
coastal management planning horizons (e.g., 50,
100, 150 years) that account for: (1) a realistic
estimated lifetime of a given action/investment;
(2) the long-term, cumulative impacts of erosion,,
sea level rise, subsidence, and changes in storm
intensities and/or frequencies over that
timeframe; and (3) explicit consideration of
uncertainty in both the hazard information and
other factors that can lead to premature loss of
the resource or investment. Also see A.3
A more prudent approach would be to focus
recommendation on some subset of areas (criteria
for designating them TBD – can help to specify
during document drafting, if necessary) where the
risks to the public interest are too great to accept.
Promoting a national dialogue on this would be a
good first step, building off of recent efforts (e.g.,
National Academies reports).
Support a unified State setback from the marsh
line that meets or exceeds 25 feet and elevation
(NAVD) that matches the expected sea level rise
elevation.
Well intentioned rec, but ultimately these
numbers are arbitrary and impose a one-size-fitsall approach to all coastal actions. There will be
investments and uses of the coast where a
century-plus timeframe is patently inappropriate.
See comments on A.3.
Better to identify appropriate minimum standards
that reflect more realistic estimates of how long a
use/investment will be needed (no low-ball
estimates just to get favorable numbers in a
benefit cost analysis), and ensure the
consideration of the cumulative impacts of hazards
that use/investment will face over that timeframe.
See notes for A3. What would this look like? In
the past 100 years we have lost vast coastal land,
cypress forests, marshes and wetlands. Is this
policy suggesting that we only build coastal
restoration projects for areas that will not be open
water in 100 years assuming this same or more
accelerated rate?
L.4. (a) Avoid the use of hard structures to protect
shorelines and riverbanks unless No Adverse
Impact can be demonstrated, In order to support
resilience over the long term, give preference to
strategic retreat or natural/nature-based
mitigation approaches (or combinations thereof)
in all funding programs
L.4 (b) Require that funding and regulatory
decisions to armor shorelines include an evaluation
and assignment of long-term costs to mitigate
potential adverse impacts of armoring, including
erosion and scour, and loss or degradation of
NFPPR Combined comm rec and comments
Any recommendations on beach renourishment?
From S. Boehning: be supported as a viable soft
solution. Experimental (temporary) geotube
structures may be deployed to assist in identifying
where permanent hard structures could be used if
no or minimal impacts observed. Economic
reasons are valid for beach nourishsment. This is
similar to a highway that is constructed for
economic reasons…this too needs to be
maintained over time. “Healthy” beaches have
regional economic benefits, not just limited to a
few along the beach
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environmental services.
b. This is already required for federal projects.
Perhaps a more thorough analysis could be
performed and more importantly, include
monitoring to provide demonstrable proof that
assumptions were correct.
b. Great idea. I understand that one hard
armoring project 1/3 washed away in the next
storm. Since it was a mitigation project already
(which arguably failed) no PA or mitigation funds
could be had to complete it. That being said, if
armoring was required for some temporary
timeframe to protect plantings until they could
root and stabilize the soils behind the armoring,
the armoring analysis should take into
consideration the second phase.
L.5. Enforce the protection of dunes and
mangroves as required in NFIP regulations
We who are new at having a climate to support
mangroves could benefit from discussion with
historical mangrove communities about the
environmental needs of mangroves/buffer zones,
soils, temperature range, etc. and what soil
building can be expected from the life cycle. With
that we might use plantings as soft infrastructure
for a living mitigation measure rather than riprap
or other structural methodology.
Alternative: types of natural infrastructure and
function that provides flood risk reduction be
protected and restored (where appropriate) as a
cost-effective strategy. Alternatively,
L.6. Provide more funds for purchase of barrier
islands and easements on barrier islands, leverage
existing funds after a disaster
Not sure how effective this will be. Would like to
know how this is working in NJ/NY after Sandy.
Loss of tax base is biggest hurdle.
From Steve Eberbach: Within the coastal
recommendations, I would advocate a
requirement that a specific percentage of postcoastal-disaster funding be used for these types of
purchases / buyouts. 25% could be proposed.
This could fit in this recommendation or others.
L.7. Require comprehensive planning for coastal
acquisition; Require acquired lands to be dedicated
to resource restoration and enhancement to
increase level of natural protection, and also to
NFPPR Combined comm rec and comments
Create incentives for States that have established
shoreland standards that protects the natural
functions and system. E.g. setbacks
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promote public access to public trust lands.
L.8. Modify National Estuarine Research Reserve
provisions to allow acquisition of uplands
At a minimum enforce CBRS
L.9. (a) Expand the Coastal Barrier Resource
System (CBRS) protection regulations, area and
physical features description.
a. What do we mean by this? Add more land to
the CBRS? Or expand CBRS rules?
b. A necessary component of this is to support
modernization of the existing CBRS map inventory.
Accurate maps are essential to proper
enforcement of current prohibitions. FWS and
FEMA have been working on this for several years,
and the Sandy Supplemental provided a huge
boost to accelerate the process. However, much
work remains, and funding is always difficult to
come by. ASFPM should specifically support this
effort first, and expansion of the program second.
L.9. (b) Review and Strengthen
monitoring/enforcement /penalties for noncompliance of provisions of the Coastal Barrier
Resources Act
L.10. Oppose efforts to remove protected natural, CBRS are mapped based on engineering science,
wilderness or federally owned areas from Coastal
prevent lands to be removed just so flood
Barrier Resources System
insurance and federal funds are available.
L.11. (a) Map and require communities to manage
coastal erosion hazards just like flooding, if it is to
be covered by flood insurance. X-ref this with
similar rec’s in other sections-LL
L.11 (b)Delineate all erosion hazard areas, both
coastal and riverine, on FIRMs in order to increase
awareness of erosion hazards and vulnerability
among property owners and local governments.
a. From S. Boehning: Okay when flood related.
Local-federal management disconnect will need to
be addressed to implement this.
a. Are we calling for more explicit consideration of
erosion risk in NFIP rates? (There’s already some
loading applied to V Zone policies to account for
erosion-related losses, stemming from results of
2000 Heinz Center Study.) yes, but the factor is
applied uniformly, not specific to location, so
equity is an issue unless corrected--LLIf so, then
that rec needs to be directly stated, and the issue
of mapping/mgmt. follows off of it (instead of vice
versa, which is what’s here now).
If we’re not calling for such a rec, then does this
recommendation to map/manage erosion risks go
away? L.11(b) seems to still call for
mapping/awareness building. These two recs need
to be better integrated.
b. Interesting perspective. I would support this
information on the maps, but would expect the
local government and current owners and users to
be a source of the information, not the newly
educated. The buyers and developers would be
NFPPR Combined comm rec and comments
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educated and planners would be able to use this
information to best direct development or lack of
development.
L.12. Evaluate coordination among all federal
agencies and coastal states of coastal zone
management, floodplain management, and
emergency management and identify actions to
minimize conflicts, align programs and missions,
and increase efficiencies.
In contrast to other recommendations in this
document, this rec is huge in scope/scale and so
lacking in specifics (i.e., who should do it, are there
focus areas around known conflicts, etc.) that I
have a difficult time seeing it implemented.
There’s nothing wrong with the concept, but it just
seems too broad as written. Perhaps assign study
to FIFIM-TF or Dig Coast-LL
L.13. (a) Provide incentives to encourage coastal
communities to have functional evacuation plans
and/or to encourage that approval of coastal
development be contingent upon provision for
warning and evacuation plans Also see F.12, F.13,
F.14
Sounds good.
.
L.13 (b) Require warning and evacuation plans be
tested annually and those tests involve
businesses and the public to improve public
awareness.
L.14. Plan build, retrofit and rehabilitate highways
to consider evacuation of the communities they
serve
Also phrased “Plan, design, and build highways
and other transportation networks to meet
current and future community needs to effectively
evacuate the population in events up to and
including the 0.2%-annual-chance event “
Edits to this rec came from Steve Eberbach. I
question whether to reference a specific event
threshold, or to revise this to be more generalized
around a “worst probable event” or similar.
Hurricane Evac Studies by USACE/NOAA and states
don’t use probabilistic flood elevations like .2%
event, but other modeling approaches; we
shouldn’t seem to suggest a change to that unless
we have good [scientific] reasons.
Any Department Of Transportation project that
changes the floodplain to include Stormwater
features and fill must?? submit LOMC even if the
increase is below 1 foot rise.
L.15. Improve public awareness of coastal risks
and natural resources and functions,
preparedness, and evacuation
Who?? How??
L. 16. Improve coastal flood maps by integrating
bathymetric and topographic maps to show storm
surge, wave runup,, overland wave hazards,
MH-This suggests current studies do not include
such data, but they do. What’s the real
recommendation here? Are we calling for more
NFPPR Combined comm rec and comments
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tsunami hazards (where applicable), erosion
hazard area and increased water surface
elevations from future conditions
detailed data? More current data? Unless there’s
a more specific angle to this rec, it’s really nothing
more than a call for better mapping. In that case,
does it belong here, or in section A? or both? LL
Maria: This needs clarification/refinement. What’s
“all buildings”? Which “storm surge zones”? NFIP
policy already mandates coverage for structures
w/ federally backed mortgages in the 1%
floodplain to be covered. Is this another instance
of an ASFPM rec founded on erroneous belief that
storm surge is not a hazard considered in
FISs/FIRMs?
Or are we actually calling for expanding mandatory
purchase to more/different buildings located in
some larger flood-prone area? If this is the case,
there needs to be a much broader policy
discussion about where to expand mandatory
purchase – not just a coastal issue.
L.17. Evaluate the impact of making flood
insurance mandatory for all buildings in coastal
storm surge zones
Property ownership is voluntary, and unless the
decision privatizes a public good to the detriment
of the public, I don’t see a reason for the
government to increase the forced placement of
insurance. To some extent, we would be better off
to refuse insurance to camps (many not actually
built to any building code standard) or other
substandard structures in an effort to encourage
the decommissioning of those unsafe structures.
Insurance encourages people to rebuild when they
might not have been able to afford to without it.
People with camps sometimes pocket the
insurance doing minimal repairs and make a profit
on the insurance proceeds. There is no limit to the
number of times people can flood and get claims
paid, and no connection between these claims
numbers or values and the flood insurance
premium. Requiring all structures to get flood
insurance will get in revenue, but also increase
payments and eliminate the incentives to mitigate
that risk or pay off mortgages to eliminate the
burden on the NFIP. FEMA must then stand firm
and not pay disaster funding to people who were
not insured encouraging rebuilding in place.
L.18. LiMWAs should not be optional and should
be used on all coastal maps. See A 21 latter is
covered elsewhere
NFPPR Combined comm rec and comments
LiMWA should be implemented…but should also
be subject to mitigation by engineering methods
to permit “removal” from SFHA where
demonstrated. Slippery slope-LL
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From Steve Eberbach: For some communities,
there are instances where LiMWA mapping is not
particularly useful. Therefore, I don’t entirely
agree that all communities should be required to
show the LiMWA. In addition, while FEMA has
made significant improvements to LiMWA
mapping practices via release of Operating
Guidance 13-13, there remain inconsistencies and
challenges in development of these delineations.
Until LiMWA mapping practices have been further
tested and applied, I recommend a softer tone to
this recommendation, where communities are
strongly encouraged to show LiMWA mapping on
FIRMs, but not required.
I prefer a V design regulation, pile, no fill,
engineered foundation, but a compromise will be
to allow A zone regulation with the exception of
must have sealed engineering foundation and
construction method.
LiMWA should be shown regardless of map scale
of the paper FIRM. FEMA has been reticent to
show the LiMWA where shorelines are relatively
steep because the lines would be printed “close”
together on a the FIRM panel. This is
unacceptable since the Digital-FIRM would give the
builder and local official the ability to zoom in and
make an appropriate parcel scale decision. We find
that many of the waterfront properties are very
small and the need to be reviewed at a larger
scale.
L.19. Local floodplain ordinances for communities
exposed to coastal flood hazards should include a
construction freeboard requirement which
corresponds to, at a minimum, the projected 50yr increase in sea level that is based on the bestavailable historical local relative sea level rise
projection published by the National
Oceanographic and Atmospheric Administration.
MM—see the FB rec in NFIP Dev stds—F
We say 3-4 feet in coastal areas
L.19. Develop a coastal A Zone definition and
provide that definition in the CFR. See F.22
NFPPR Combined comm rec and comments
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